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2.
EURACOAL page 2 of 31 17 August 2018
Executive Summary
EURACOAL has been asked by the National Energy and Utilities Regulatory Commission of Ukraine
(NEURC) to give its opinion on an official coal-pricing methodology introduced in 2016. The
calculated steam coal price is used when setting regulated electricity tariffs in Ukraine on the
assumption that owners of thermal power plants will then receive enough income to purchase their
coal needs, some of which must be imported.
Historically, Ukraine has been able to meet most or all of its own steam coal demand and has even
enjoyed short periods when it was a net exporter of steam coal. More recently, the country has had
to rely on imported steam coal, following the loss of coal mines due to the ongoing conflict in
eastern Ukraine.
This report provides a background to price formation on the international steam coal market, based,
as it is, on the balancing of supply and demand at a market price. It shows that Ukraine is a small
player in the huge international coal market and is therefore a price taker. For any free-market
economy that is a net importer of coal, the price of imported coal from the international market,
including shipping costs, sets the national price for coal producers. For countries that are net
exporters of coal, this is also true, but without the cost of international shipping.
To establish a transparent benchmark price for imported steam coal, NEURC chose the API 2 coal
price index, this being a combination of the prices reported independently by two commercial
providers of coal-market information in the Argus/McCloskey Coal Price Index Report. Specifically,
API 2 reflects the price of steam coal imported into northwest Europe at three major ports:
Amsterdam, Rotterdam and Antwerp (ARA). This choice of marker price is entirely correct. The
collection and reporting of the underlying price data is trusted by market participants around the
world and the methodology used is fully specified and properly scrutinised.1
The cost of shipping coal to Ukrainian ports is higher than to the ARA ports. EURACOAL has taken
advice from market experts and believes that the cost delta was up to US$9/t in November 2017,
depending on the origin of a particular shipment and vessel size. However, there is very little trade
upon which to confirm cost estimates. The estimates of the shipping cost deltas used by NEURC
ranged from US$6.5/t to US$14.5/t between January 2016 and June 2018. We conclude that the
assumed shipping cost deltas used by NEURC are of the correct magnitude.
Ukraine’s coal import needs are slightly complicated by the requirement for low-volatile coal, such
as anthracite, at some Ukrainian power stations. The international market for such coal is shallow,
with few marker prices. The conversion of some power stations to burn widely traded steam coal
has alleviated this complication. Also, the price of low-volatile coal can be similar to that of steam
coal for power generation, depending on demand from the steel industry where low-volatile coal
commands a higher price.
In conclusion, the choice of marker price is correct – the API 2 is a transparent and appropriate
measure of the import parity price in Ukraine. The transport cost add-on in the so-called
Rotterdam+ price formula is an approximation and may not reflect the actual cost of delivering coal
to Ukrainian ports. However, like the API 2 marker price itself, the transport cost delta must be
estimated transparently. Adding a transport cost delta to the agreed, indexed coal price to arrive at
an import parity price means that future variations in coal and transport costs can be captured.
1
Thermal Coal and Petcoke Marker Price Methodology and Specifications, IHS Markit Ltd., July 2018 and
Methodology and Specifications Guide, ARGUS Coal Daily International, Argus Media Group, August 2018.

4.
EURACOAL page 4 of 31 17 August 2018
1. Introduction
This report offers an analysis of world coal markets and best practice for coal producers and
importers to remain competitive. It is prepared in response to a request dated 18 July 2018 from
the National Energy and Utilities Regulatory Commission of Ukraine to give our opinion on a coal
pricing methodology introduced in 2016.
The report begins with an introduction to EURACOAL and the association’s position on markets and
subsidies. Some basic economic terms are introduced to explain the formation of steam coal prices
on the international market. Then, the coal supply situation in Ukraine is examined before
explaining the pricing methodology introduced by the Ukrainian government in 2016.
Subsequent sections of the report assess this pricing methodology from a purely objective
viewpoint. We offer no opinion on any political decisions. An overview of world coal production
(supply) and consumption (demand) in Section 2 aims to show the Ukrainian coal industry in the
broader context of an enormous, global coal industry that is set to grow even bigger. International
coal pricing is then explored, with a history of price indices in Section 3 and their growing
importance to coal trade. A review in Section 4 of coal pricing in seven countries offers insights into
how governments have sought to balance a desire for more market liberalisation with the need to
protect often large, indigenous coal industries.
In Section 5, the report turns to the situation in Ukraine where administrative coal pricing led
ultimately to a crisis in the coal industry. This crisis became even more severe as coal mines where
lost due to the conflict in the East and the consequent need to import coal to meet demand.
Without enough income to pay for imported coal, electricity generators became “pig-in-the-middle”
– without the financial resources to meet their commitments to supply. In response, to this crisis,
the National Energy and Utilities Regulatory Commission of Ukraine proposed a new pricing
methodology for coal. Adopted in 2016, this methodology provides owners of thermal power plants
with a regulated electricity rate that should enable fair fuel costs (coal, oil and gas) to be passed
through to electricity consumers. The methodology is based on an import parity price and is
described and assessed in Section 5 of this report. This assessment feeds into the report’s key
findings presented in Section 6 and conclusions in Section 7.
1.1.EURACOAL – the voice of coal in Europe
In 1954, the “Comité d’Etude des Producteurs de Charbon d’Europe occidentale” (CEPCEO or the
“Western European Coal Producers’ Association”) was established. EURACOAL itself was established
in 2002 as a successor association to the “Comité Européen des Combustibles Solides” (CECSO or the
“European Solid Fuels Association”) which itself succeeded CEPCEO in 1996. Today, EURACOAL
represents twenty-six members from fifteen countries.
1.2.EURACOAL on markets and subsidies
In the preamble to the EURACOAL statutes, the European coal and lignite industry states that it
wishes “to continue to participate actively in the development of Europe’s energy market by joining
forces with other central organisations within the energy sector and with the institutions of the
European Union”.
This belief in markets and market-based solutions has underpinned EURACOAL activities since 2002.
That does not mean that EURACOAL is fundamentally against subsidies. These are paid in some EU
member states and elsewhere for a variety of reasons, such as to support renewable energy sources.

5.
EURACOAL page 5 of 31 17 August 2018
EURACOAL is against the payment of subsidies which disrupt market outcomes. So, for example,
hard coal mining in Germany has received generous subsidies over the years to mitigate the social
consequences of the long-term decline of a large industry. Despite these subsidies, a competitive
coal market continues to exist in Germany, because the subsidy mechanism pushes indigenous
producers to sell their coal at an import parity price (see Box 1). Conversely, the payment of
generous renewable feed-in tariffs in many EU member states, including most notably Germany, has
depressed wholesale electricity prices to levels that damage competing sources of electricity.
Box 1 – Selling price of subsidised coal in Germany
German hard coal production is structurally uncompetitive, with high production costs reflecting the
great depth (up to 1 500 metres) from which coal has been recovered by the country’s only hard coal
mining company, RAG AG. In 2011, the European Commission agreed the German government’s
plan to close all the remaining hard coal mines by 31 December 2018. This plan includes the
payment of substantial State aid, including aid of almost €6 billion to cover current production costs
over the eight-year period 2011-2018 (i.e. almost €100/tonne).
In order to determine the amount of State aid a coal undertaking is entitled to, Germany has issued
a special implementing legislation, the so-called “coal guidelines” (Coal guidelines of the Ministry for
Economy and Labour of 8 April 1998 (Bundesanzeiger of 7.5.1998, p.6509) modified on 2 August
1999 (Bundesanzeiger of 2.9.1999, p.15265)), which define how State aid for the German coal
industry is calculated. This calculation is carried out by the Federal Office of Economics and Export
Control (BAFA).
According to the German BAFA price system, aid may only be granted up to a maximum made out of
the difference between revenues and costs for steam coal (Verstohmungskohle) and coking coal
(Kokskohle), plus closure costs. These payments are however limited by the average sales price of
imported hard coal, the BAFA reference price. Thus, there are two possible situations (see also
Figure 1):
Situation A: If the sales price for German hard coal is lower than the average sales price for
imported hard coal, cost compensation by BAFA can only cover the difference
between a hard coal mine’s production costs and the average sales price for hard coal
imported from third countries.
Situation B: Should the average sales price for German hard coal be higher than the average sales
price for imported hard coal, then only the difference between the production costs
and the average sales price for German hard coal may be compensated by BAFA.
The price calculated by BAFA for hard coal imported from third countries reflects the world market
price for hard coal. To perform this calculation, BAFA collects the monthly prices (free delivery to
the German border) of imported steam coal, coking coal and pulverised coal injection (PCI) coal.
Source: European Commission Decision C(2011) 8882 of 07.12.2011 on State aids SA.24642 (N 708/2007) for the closure of
hard coal mines in Germany and SA.33766 (11/N) notification of aid to coal for 2011 published on 20.09.2012 (OJ 2012/C
284/02 pp.6-10).

6.
EURACOAL page 6 of 31 17 August 2018
Figure 1 – German hard coal subsidies are capped so that coal does not appear on the market at
prices below (or above) the import parity price
The only producer of hard coal in Germany is RAG AG. The company would make a loss if it dumped coal on the market
because the subsidy payment is linked to the import parity price. If coal is sold at above the market price, then the subsidy
is reduced as the power generators effectively then subsidise the coal producer. Neither situation A nor situation B is
therefore likely – RAG AG will try to sell coal at a market price equal to the import parity price.
1.3.Coal market economics 101
In a free-market economy (freie Marktwirtschaft), the equilibrium price is generally set by the
variable cost (or long-run marginal cost or cash cost) of the last producer that is needed to meet
demand. Every producer then receives this price. An illustrative cost curve for the international
steam coal market is shown in Figure 2 with a presumed demand curve that intersects at a price
close to the average in 2016.
Some people might question why producers with lower costs do not sell at lower prices for the
benefit of society as a whole – those on the left, such as in Colombia. Their costs are low because
they are more productive, reflecting a significant capital investment in coal mine projects (e.g.
deposit exploration, acquisition of mineral rights, acquisition of land or access rights, mine
development, automated machinery, transport infrastructure and facilities for workers). Coal
producers also face land restoration costs and other liabilities, such as subsidence damage. It is the
difference between selling price and variable cost that allows full cost recovery and encourages
investment. Without this incentive, there would be no investment and no productivity gains; costs
(and prices) would be higher and consumers would be worse off.
Coal mining costs might also be low because a particular coal resource is easily accessible. This is the
case at some large surface mines with shallow, but thick seams, for example in the Powder River
Basin in the USA. In all mining projects, the question of valuing mineral rights arises. These are
often state owned and mine owners pay a royalty, either a fixed, tonnage-based levy or an
individually negotiated rate. These payments, as well as the many taxes paid (on value added,
property, employment and profit), mean that coal mining operations make a wider contribution to
society.
In a planned economy (Planwirtschaft) or command economy (Befehlswirtschaft), the state allocates
capital and sets prices which may be lower or higher than a free-market price. In this situation,
there is no incentive and no liberty to invest privately, because all investments are state planned;
natural resources and the means of production are state owned. Political decisions may allow
consumers to benefit from low prices, but businesses may then not be economically sustainable.
Problems arise at the interfaces between command economies and the international market place
(e.g. coal import-export restrictions imposed by China which has a mixed economy, being partly
planned).
subsidy
subsidy
Situation A Situation B
hard coal production cost
in Germany
coal sale’ s price
hard coal import parity
price (average BAFA at
German border

7.
EURACOAL page 7 of 31 17 August 2018
Figure 2 – Supply and demand curves for international steam coal market: FOB cash costs for
global seaborne steam coal trade and a presumed demand curve in 2016
Source: World Energy Outlook (IEA, 2017) using data from CRU Thermal Coal Cost Model and demand curve estimated by
EURACOAL
1.4.Coal pricing in Ukraine
In Ukraine, a discussion is taking place on the correct price for coal. From the foregoing, it is clear
that, as a net coal importer, the “correct” market price from an economic perspective is an import
parity price. The National Energy and Utilities Regulatory Commission of Ukraine therefore
proceeded to establish a methodology to calculate the import parity price for coal (see Box 2) and
now includes this coal price in the cost base when setting electricity tariffs in Ukraine.
This report explores the options for setting an import parity price and offers a critique of the method
chosen by the NEURC.
Box 2 – Description of NEURC formula for establishing an import parity price for coal in Ukraine
An English translation of the Ukraine government Decree No. 289 of 3 March 2016 that establishes a
methodology for calculating the import parity price of coal can be found at Annex 1. In summary,
the methodology calculates a coal price at the Ukrainian border:
Price at Ukrainian border = average API 2 + average transport costs
Where:
▪ “average API 2” is the average All Publications Index #2 for the last twelve months
▪ “average transport costs” is the average freight cost for the last twelve months plus the
average cost of vessel unloading and inland rail transport to stockpiles at power stations
The stated aim of this NEURC formula is to provide a temporary market indicator for the transitional
period leading to full liberalisation of the energy sector, in accordance with the coal industry
liberalisation plan. The plan aims:
▪ To establish an indicative market price for the transitional period.
▪ To use close-to-market prices that allow coal mine owners to invest and improve
performance.

8.
EURACOAL page 8 of 31 17 August 2018
▪ To create equal conditions for both domestic producers and importers (previously, the
administrative price was lower than the price of imported coal).
▪ To develop healthy competition in the coal market.
▪ To improve and develop the coal industry.
To illustrate the smoothing effect of the twelve-month rolling average price formula, Figure 3
compares the calculated import parity price with import spot prices.
Figure 3 – Comparison of steam coal import prices in northwest Europe (NWE), marginal mine
production costs at state-owned mines in Ukraine, administrative coal price and NEURC formula
Sources: EURACOAL analysis (NWE import price range and NEURC formula-based price); NEURC data (average production
costs at state-owned mines for commercial-quality coal and administrative coal price). Shipping cost deltas (US$6.5/t to
US$14.5/t) and port-handling charges (US$6.75/t to US$7.85/t) are as published in “Industrial Cargoes”, Metal-Courier,
Metal-Expert LLC (www.promgruz.com).
1.5.Coal industry structure in Ukraine
The EURACOAL publication Coal industry across Europe (6th
edition and previous editions) offers an
overview of the coal industry in Ukraine which comprises a mix of private and state-owned coal
mines.
On the Ukrainian market, steam coal is divided in two groups: anthracite grades (А and P grades
with the highest calorific values or heating values of all coal grades) and high-volatile steam coal (G
and DG grades). Steam coal in Ukraine is mined in the Donetsk and Lviv-Volyn coal basins.
Anthracite reserves are concentrated in Luhansk and Donetsk regions. Coal supplies from Luhansk
and Donetsk have been temporarily suspended since March 2017 on account of the ongoing conflict
in those regions. The loss of these anthracite resources drove power producers to re-equip power
plants with steam coal burners. This increased the demand for steam coal, leading to shortages and
import dependency.
0
500
1000
1500
2000
2500
3000
3500
UAH/t, 5 200 kcal/kg
NWE+ (daily max in month)
NWE+ (montly average)
NWE+ (daily min in month)
state-owned mine cost
admin price
NEURC formula

9.
EURACOAL page 9 of 31 17 August 2018
This report focuses on steam coal only. It is noted here that the market for anthracite is much less
developed. Anthracite is a premium product attracting higher prices, especially in the heating
market, and therefore is less widely used for power generation.
Traditionally, Ukraine has produced enough indigenous coal to satisfy demand. As a result of the
ongoing conflict in the East of the country, coal mines have been lost and production has fallen such
that imports are now required to balance demand, as shown in Figure 4.
Figure 4 – Steam coal production, net imports and supply in Ukraine, 1990 to 2016
Source: IEA World Coal Supply database, OECD International Energy Agency, Paris, accessed 9 August 2018.
Given the massive drop in the value of the Ukrainian currency, the hryvnia (UAH), as a result of the
conflict, the dollar cost of most privately owned Ukrainian coal production is internationally
competitive (Figure 5). State-owned mines continue to be subsidised.
Figure 5 – USD / UAH exchange rate
Source: National Bank of Ukraine (average weighted exchange rate in the interbank foreign exchange market of Ukraine)
0
5
10
15
20
25
30
01/01/2013 01/01/2014 01/01/2015 01/01/2016 01/01/2017 01/01/2018

10.
EURACOAL page 10 of 31 17 August 2018
1.6.Market price for coal in Ukraine
If we assume that market participants (buyers and sellers) act rationally, then coal prices in Ukraine
would be set by the marginal cost of the last supplier. Today, that price would be set by a supplier of
imported coal. In a free market, the state-owned mines would fail, but with subsidy they remain on
the market and can sell at below their cost price.
Figure 6 illustrates two situations: one where indigenous producers meet all demand and another
where imports are required. The market price is higher in the latter case, but subsidy payments to
state-owned mines can be lower. With higher market prices, private coal mines earn higher profits
and can invest to maintain their competitiveness against imports. If they fail to invest, then they risk
becoming uncompetitive and failing as buyers switch to cheaper imports.
Figure 6 – Examples of subsidised state-owned mines, loss-making private mines and profitable
private mines in Ukraine
The size of subsidy paid to state-owned coal mines reduces as the import parity price increases. At the same time, the
profitability of private mines improves. If private mines are loss making for long periods, they will fail and close, so they
must invest to maintain their productivity and hence competitiveness.
2. World coal supply and trade
This section examines the global steam coal market from a supply and demand perspective, and how
coal trade leads to price formation in a liquid market.
2.1.Overview of world coal supply and demand
The vast majority of the seven billion tonnes of the coal produced globally each year is consumed in
the country in which it was produced. Coal is categorised by rank depending on its carbon content,
and ranges from anthracite with a very high carbon content, through bituminous and sub-
bituminous coals, to low-carbon lignite or brown coal. Of the total volume of coal produced an
average of 5.5 billion tons (4.5 Btce) is made up of thermal coal and lignite.
Approximately one billion tonnes is exported, either by rail to neighbouring countries, or by sea. Of
the seaborne trade, whilst some is metallurgical or coking coal used in the steel industry, the largest
part is made up of thermal or steam coal. This is used primarily to produce heat, hence its name,
and includes both bituminous and sub-bituminous coal. Lignite is rarely exported because its energy
content is low, meaning the cost of transport makes it uneconomic to move any great distance. It is
usually used very close to where it is mined.
subsidy
subsidy
Jan 2016 Jul 2018
hard coal production cost
at state-owned mines
coal sale’ s price = import
parity price
hard coal production cost
at private mines
profit
loss

11.
EURACOAL page 11 of 31 17 August 2018
The world’s largest three producers of coal are China, the USA and India. Despite being the world’s
single largest coal producer, China is a net importer, selling only small quantities of coal overseas.
The USA exported just over 10% of its production in 2017. India does not export, but is a major
importer of thermal coal for its newly built coal-fired power stations, and of metallurgical coal for
steelmaking.
Figure 7 – World coal supply and demand
Source: IHS McCloskey
2.2.World coal supply and demand projections
High oil and gas prices over the last three years have created confidence in the continuing growth of
coal demand around the world.
A lack of sufficient gas trading infrastructure and accessible coal reserves in such large, energy-
consuming countries as India, China and ASEAN countries, support the expected increase of coal
demand in the future.
Electricity demand for coal in Europe is expected to decline due to a lower growth of energy
consumption, in general, and extensive gas-trading infrastructure, both for pipeline gas and LNG,
which allows coal to be easily substituted.
Additional factors supporting the expected curtailment of coal demand in Europe are the EU’s
stringent environmental regulations and the strong growth of subsidised renewables.
World largest thermal coal & lignite
producers in 2016, mtce
457
(11%)Austarlia
US
400
(9%)
290
(7%)
China1 878
(44%)
Others
386
(9%)
Russia
572
(14%)
Indonesia
India
238
(6%)
World largest thermal coal & lignite
consumers in 2016, mtce
782
(18%)
Russia 185
(4%)
EU
497
(11%)India
Others
China
280
(6%)
US
2 109
(49%)
478
(11%)
Top steam coal exporters, 2017, mtce Top steam coal importers, 2017, mtce
Taiwan
China
90
(16%)
58
(11%)
28
(5%)
20
(4%)
GermanyTurkey
123
(23%)
99
(18%)
South Korea
Japan
128
(23%)
India
71
(9%)
171
(22%)
Australia
325
(41%)
Russia
USA
South Africa
70
(9%)
Colombia
120
(15%)
Indonesia
32
(4%)

13.
EURACOAL page 13 of 31 17 August 2018
Figure 9 – World steam coal production projections, Mtce
Source: IEA, Coal 2017 Analysis and forecasts to 2022
2.3.World coal trade and prices
Seaborne coal trade is based around two major basins: the Pacific and the Atlantic. The geographic
locations of the major coal exporters determine the key markets for each country’s sales, although
trade flows do extend beyond their immediate near neighbours. Major exporters, such as South
Africa, are able to direct their attentions east or northwest according to where they see the best
returns. As a result of increased competition in the European coal market. notably from Russia via
Baltic ports and Colombia, there has been a marked shift in South African exports to the Indian sub-
continent, in direct competition with Indonesia.
The largest importers in the Atlantic Basin at the present time are Turkey and Germany. The
successful growth in some countries of renewable energy sources such as wind and solar, the
widespread availability of natural gas following the successful exploitation of shale gas in the USA
and new fields in the North Sea, and the introduction of punitive measures to penalise electricity
generation that creates high CO2 emissions, i.e. generation from fossil fuels, has caused a shift in the
relative importance of European coal importers. Historically large importers of coal in the European
market such as the UK have almost entirely closed their coal-fired fleet, and the few remaining coal-
EU Thermal coal & Lignite production, mtce
178 164 154 147 145
2015 2016 2018 2020 2022
592 487 525 506 484
182 169 159 154 153
243 238 227 226 238
2030
1878 1983 2010 2035
372
386
439 479 516
395
400
413 404 396
320
327
326 335 343
330
336
326 335 345
2015 2016 2018 2020 2022
OECD Americas OECD Europe OECD Asia China
India ASEAN Easten Europe Others
4 464
4 221
4 398 4 449 4 510

14.
EURACOAL page 14 of 31 17 August 2018
fired power stations in the UK will be forcibly retired by 2025. In reality, they will be forced to close
beforehand for economic reasons.
Figure 10 – World seaborne steam coal trade in 2016
Source: IEA, Coal 2017 Analysis and forecasts to 2022
The global coal market consists of two main consumer markets: northwest Europe and the pan-
Asian market.
These markets are the primary centres of price formation owing to the high demand for imports
caused by insufficient domestic supply.
South African (and to some extent Russian) producers are able to balance their exports between
these two markets to realise the best prices for their coal sales.
Figure 11 – Regional col price trends
Source: IHS McCloskey Coal Report
0.00
20.00
40.00
60.00
80.00
100.00
120.00
API-2 API-4 Asian Marker
$/t

15.
EURACOAL page 15 of 31 17 August 2018
3. Coal price indices – 1990s to the present day
The so-called “All Publications Indices” (API) are trusted and used by coal professionals around the
globe, with more than 90% of the world’s traded coal derivatives using the API 2 and API 4 indexes.
 API 2: The industry standard reference price for coal imported into northwest Europe
 API 4: The price for all coal exported from Richards Bay Coal Terminal, South Africa
 API 5: The price of NAR 5 500 kcal/kg, high-ash coal exported from Australia
 API 6: The price of NAR 6 000 kcal/kg coal exported from Australia
 API 8: The price of NAR 5 500 kcal/kg coal delivered to south China
 API 10: The price of NAR 6 000 kcal/kg coal exported from Puerto Bolivar port, Colombia
 API 12: The price of NAR 5 500 kcal/kg coal delivered to east India
Figure 12 – API 2 and API 4 dominate coal trade
3.1.The evolution of coal trading
Until the early years of this century most seaborne thermal coal was sold under bilateral
arrangements between a producer and a consumer (power generation company). There were
physical traders in the market, including multi-commodity trading houses such as Glencore and
Phibro (later Noble) and smaller, coal-only traders such as Anker, SSM and Bulk Trading. These
companies had traditionally enjoyed long-standing relationships with buyers, suppliers or both;
some traded on a back-to-back basis, but some larger ones took market risk, looking to profit from
their expertise, gradually competing more and more with producers. During the late 1990s, some
larger trading houses started to invest in coal-producing assets to ensure their ongoing supply, while
producers attempted to do more direct marketing and exclude traders. At this time, the role of a
broker, a party that would bring together a buyer and a seller without taking any market risk at all,
did not really exist in the seaborne coal market. Information about current market prices was
therefore much less freely available and less transparent than it is today.
The European power sector had comprised a relatively small number of large, often state-owned or
state-controlled, highly regulated power generation companies, usually operating within national
boundaries, linked to a distribution system to ensure power reached consumers. Following the
gradual liberalisation of the power markets, beginning in 1990 with the UK, the structure and
ownership of power generation assets started to change. The development of CCGTs (combined-

16.
EURACOAL page 16 of 31 17 August 2018
cycle gas turbines) led to an oversupply of generation capacity in some countries and, for the first
time, coal buyers started to put economic competitiveness ahead of security of supply when
considering their coal-purchasing strategies. Power stations that had previously run on a base-load
regime were forced to compete simply to stay in the market.
With the change in emphasis away from security of supply and central generation in each country,
towards competitively priced electricity for sale in free markets that stretched across national
borders, came a change in behaviour and buying patterns among coal consumers. Although the
Asian market was much slower to adopt the principles of market liberalisation, as described below in
the section on Japan, European buyers quickly began to reject the notion of fixed price coal
contracts that could hinder their competitiveness in the electricity market. If a power generator was
still obliged to take delivery of coal at a high, fixed price when the spot price had fallen several
dollars such that its competitors were able to buy coal more cheaply, then it would not be able to
compete in the electricity market.
3.2.Background to implementing coal price indices
The chart in Figure 13 shows how relatively stable the coal price was in the early to mid-1990s,
reflecting the fact that many coal contracts were still priced for medium- to long-term periods. As
the growth of spot trades emerged and companies started to deal on shorter terms, more market-
based activity took place and prices became more volatile. For example, between Q2 2003 and Q3
2004 the coal price more than doubled, something not seen in the previous decade.
Figure 13 – API 2 price dynamics, US$/tonne
These developments led to the need for mechanisms to manage fuel-price risks. Previously, any
increase in input costs such as a rise in coal prices could often be recovered through an increase in
the electricity tariff, as it remained in any country’s national interest to ensure that its electricity
supply chain continued to function. The much more liberalised structure that began to emerge in
several European countries meant that this old order no longer prevailed. A merchant power
generation company had to be able to operate in a competitive environment, including competing
against different fuels such as natural gas. It was this that led to the successful adoption and
acceptance of the various coal price indices that several organisations had been trying to bring to the
coal market for several years.
3.3.Indices and financial coal trading
The most significant change to take place in the last twenty years has been the successful
introduction of financial coal trading. This developed as a direct result of competition in the
electricity sector; if it is no longer possible to recover an increase in the cost of coal or gas in the
0
20
40
60
80
100
120
140
160

17.
EURACOAL page 17 of 31 17 August 2018
electricity tariff, then it becomes essential to have a mechanism by which the power generation
company can ensure it is not exposed to a financial loss. For that reason the traditional practice of
buying coal at a fixed price under long-term contracts was no longer suitable for power generators
trying to sell electricity into a dynamic, competitive market.
The most essential element of a financial trading system is an independent, verifiable spot index
against which the financial transactions are settled. It must reflect the value of the commodity in
the current spot market, and the market must have confidence in its integrity and support it with
liquidity. By using financial contracts, or swaps, commodity market participants can separate their
physical risk from their financial risk and manage them individually.
The index adopted by the European coal market was the API 2. API stands for All Publications Index,
and the API 2 is the average of the daily price assessments by IHS McCloskey Coal and Argus Media
for coal of a standard quality (6 000 kcal/kg NAR – net as-recieved) to be delivered in a certain
(prompt) timeframe into northwest Europe. The daily assessments are averaged and published
weekly on Fridays; the average of these weekly values becomes the monthly value and is used in the
settlement of swaps.
The practice of linking physical deals to an observable index has spread since the birth of the API 2 in
2001. In South Africa, the API 4 is the price for a standard coal (6 000 kcal/kg NAR) loaded FOB at
Richards Bay Coal Terminal (RBCT). API 8 is the price index for lower grade coal (5 500 kcal/kg NAR)
CFR South China assessed by IHS McCloskey, Argus Media and Xinhua Infolink, whilst globalCOAL
NEWC is the recognised price index for a standard coal (6 000 kcal/kg NAR) loaded FOB Newcastle,
NSW in Australia.
Other indices have also developed, but not all have been successfully used as settlements for
financial trading. In that sense, many of these other indices can be more accurately referred to as
marker prices. Several different organisations, including brokerage firms and publishers of trade
magazines, have launched their own marker prices and publish them, all hoping to have found the
next API 2, but only the handful listed above have really taken off and have any liquidity behind
them. For this reason, only those indices are typically used in coal contracts around the world.
Clearly, both buyers and sellers want to know that the indices to which their purchasing and selling
arrangements are going to be linked are widely used and cannot easily be manipulated. It would be
unwise to agree a contract that was linked to an obscure coal price based on very few transactions
between very few parties that were very hard to verify.
Figure 14 – Coal price indices: historic milestones during the 1990s
• Most coal contracted annually
• Spot market is around 20%
• Price negotiated annually,
government regulation for
internal markets
• Need for market prices and price
indicators is growing
• Market deregulation is rising,
share of spot contracts rising
Evolution of the indices
1991
1997
2000
1st international steam coal index,
NW Europe, monthly reporting for
6,000kcal/kg NAR
Richards Bay, monthly
reporting for 6,000kcal/kg
NAR
Newcastle (NSW)
weekly reporting
for 6,000kcal/kg
NAR

18.
EURACOAL page 18 of 31 17 August 2018
In the United Kingdom, the privatisation and reorganisation of the energy sector became a major
spur for the need to find market indicators for steam coal. At the same time, other European
markets became more and more deregulated, increasing the volume of spot deals. As such, the
need for market indicators grew rapidly
Figure 15 – Coal price indices: historic milestones in the 2010s
In summary:
 The introduction of market indices in the early 1990s was the forerunner of a significant
development in coal trade. Financial coal trade volumes grew and eventually exceeded even
the most optimistic expectations.
 API 2 became the most traded index within a few years of its implementation, leading to
attempts to create new indices with similar impact.
 Today API 2 remains dominant, but API 4, globalCOAL NEWC and API 8 are also used.
Figure 16 – Main coal price indices in use today
Source: Thermal Coal and Petcoke Marker Price Methodology and Specifications, May 2017 (IHS Markit)
2000
2001
2009
Start of weekly reports of indices
Start of daily reports of
indices for NWE and
RBCT
McCloskey and Argus NWE
combined to create API#2
RBCT market reports* combined
to create API#4
• First index calculation of NW
Europe included collected prices
for coal from the main supply
indices with weighted average
for each month
• Now, NW Europe and RBCT
(Richards Bay Coal Terminal)
indices are assessed on daily
basis
• API#2 is the most traded index,
6,000kcal/kg NAR (net as
received), <=1% sulphur
Indices evaluation steps
API#2
API#4
Richards Bay
API#5
Australia
globalCOAL
Newcastle
API#12
India
API#10
Colombia
CFR North West Europe (ARA)
6,000 kcal
Most liquid
Traded on exchanges
Classic buyer’s market
Sets price for whole European
market
FOB Richards Bay, South Africa
6,000 kcal
Location allows it to trade east
and west
Limited number of sellers with
access to RBCT
FOB Australia
5,500 kcal
FOB Colombia
• 6,000 kcal
• Home of the biggest FOB seller
in Colombia.
• The price is heavily dependent
on European coal prices and
the cost of freight in the
Atlantic region
CFR East Coast India
5,500 kcal
API#3
South African
FOB South Africa
5,500kcal
API#8
South China
CFR South China
5,500 kcal
Relatively new, but has become
the main price maker for Asia
Pacific
Coal FOB NSW, Australia
6,000 kcal
Main client base for the coal
quality is japan which still buys on
term basis but the contract sees
some liquidity
OTHER MARKET
INDICATORS
INDICES USED IN
CONTRACTS

19.
EURACOAL page 19 of 31 17 August 2018
Figure 17 – Other steam coal price indices or “marker prices”
Source: IHS McCloskey Coal Report
3.4.Advantages of index-based pricing
3.4.1. Greater efficiency in the international coal trade
In 1990, most coal was sold on long-term contracts with annual price negotiations, and only 20% of
the market was transacted through spot contracts. Privatisation and deregulation in the energy
sector across most of Europe has brought greater flexibility through more dynamic pricing, with
greater transparency. This has led to a more efficient market, because buyers and sellers can see
how prices are being affected by events worldwide.
3.4.2. Risk management: separation of physical and financial risks
With long-term contracts, the coal price was fixed against a fixed volume with little flexibility to vary
the terms if circumstances changed. With index-based pricing, buyers and sellers can agree a
floating price for their physical coal and simultaneously limit their exposure to uncertainty through
hedging on the financial market. This can also assist with cash flow management.
3.4.3. Certainty about forward prices
Indexation has brought about forward curves which give the market transparency. A transparent
forward curve affords buyers and sellers a degree of certainty about future prices without obliging
them to lock their physical coal sales into long-term price deals with individual counterparties, as
was the case for most coal purchasing until the late-1990s/early-2000s. This means they can
respond to movements in electricity prices, not previously necessary under the old, regulated
market regimes. The shape of the forward curve is determined by the supply-demand balance; a
Baltic RUSSIA
Current price: FOB $82,03 (6,000 kcal, NAR)
• The main loading ports for coal from Russia to the
European market
• The prices on this site reflect the dynamics of the NW
European markets, however with a small time lag
Indonesia, Banjarmasin
Current price: FOB $101,38 (6,000 kcal)
• One of several loading locations for Indonesian coal
• Substantial increase in volumes over the last 10 years
• Separate coal price index but very illiquid
• Most sales to China and India
US East Coast
Current price: FOB $79,11 (6,000 kcal, NAR)
• The most active platform of the sea-borne coal trade
in the USA.
• The main terminal for selling coal to Europe
• The prices are heavily dependent on the API-2 index
US Gulf (high sulfur)
Current price: FOB $59,07 (6,000 kal, NAR)
• A less liquid trading platform for coal with a high
sulfur content
• Coal is not supplied to the European market
• The prices largely depend on the buyers in Latin
America and producers from Colombia and
Venezuela
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20.
EURACOAL page 20 of 31 17 August 2018
contango (higher prices in the future) generally signals a surplus, while backwardation (higher prices
in the prompt) signals a deficit.
3.4.4. Alignment with other globally traded energy products across the world
The coal market has moved to the spot trading model with index-linked contracts, aligning it with
other world energy commodity markets such as oil.
3.4.5. Further deregulation of world coal market in a world of freely traded electricity
70% of steam coal is used in electricity generation. In a world where electricity is increasingly
becoming a freely traded commodity, it is right that coal is openly traded in a free and transparent
market.
4. Global experience with coal-pricing systems
Different countries have had different mechanisms for purchasing imported coal over the years,
depending on a variety of features including the availability of alternatives (such as domestic coal)
and the structure of their domestic energy markets. It is worth noting a few examples and observing
how these have evolved over the years and will continue to evolve as the coal market becomes more
integrated and competition takes hold in the electricity markets. Below, we present several
examples of coal pricing for countries which became net importers of coal.
4.1.Japan
– traditionally fixed-term contacts for imports on a free-market basis
Japan’s coal mining industry declined rapidly in the 1980s and was replaced by imported coal,
primarily from Australia in the early years.
There are no price controls on coal in Japan, but the structure of the electricity supply industry is of
interest. There are ten vertically integrated electricity utilities, known in Japan as EPCs (Electric
Power Companies), each covering a different geographic region of Japan. There is also one large
wholesale supplier, J-Power, and numerous other wholesale suppliers, municipal utilities and smaller
generators.
Traditionally, coal was priced annually with the Australian producers in New South Wales (NSW) at
what was known as the “reference price” or “benchmark price”. This was negotiated annually
between the producers and the consumers with the help of the trading houses. The price for the
biggest volumes to be shipped over the next twelve months was agreed for the Japanese Financial
Year (JFY) from April to March, but smaller volumes were also fixed at newly negotiated prices for
the periods July to June, October to September and January to December.
With the very gradual introduction of a competitive pricing environment in the Japanese electricity
sector, buyers started to reduce their dependence on Australian coal, and buy from the abundant
production being exported from Indonesia, as well as from the growing export volumes from eastern
Russian ports.
In addition, some JPUs started buying less of their Australian requirement on the traditional fixed-
price arrangements and more on spot or short-term contracts. This has been made easier by the
accessibility of transparent pricing on the globalCOAL trading platform, which we will discuss in more
detail later in this paper.

21.
EURACOAL page 21 of 31 17 August 2018
As competition slowly starts to take effect, some of the more commercially aggressive generators,
such as JERA, are buying from further afield, such as the USA, in an attempt to secure supplies at
prices below the reference price. But Japan is an island, and its high degree of dependence on
reliable supplies of consistent quality coal means that the prices the JPUs reach with the NSW
exporters have to be sufficiently high to ensure those producers can continue in business. It will
take many years in this very conservative country to move away fully from this model.
4.2.South Korea
– free market
South Korea’s power sector is also highly dependent on imported coal and is also one of the largest
coal importers in the world. The power sector is dominated by KEPCO (Korea Electric Power
Corporation) under which sit five thermal generating companies known as Gencos, and a nuclear
generating company. The five Gencos are largely split by geography.
Korean Gencos issue tenders and buy coal of both high and lower qualities from Indonesia, Australia,
Russia, South Africa, the USA, a little from China and increasingly from Colombia. With a diversified
supply and power stations that are more flexible than Japan’s, they tend to be much more price
sensitive buyers than the JPUs.
In mid-2014, the South Korean government imposed a tax on coal imports of about US$16.20/t for
coal with less than 5 000 kcal/kg NAR and US$18.10/t for coal with a higher CV. These taxes have
been steadily increased in subsequent years.
Competitive tension exists between the generating companies, but they are very large buyers and
tend ultimately to achieve highly competitive prices.
4.3.China
– free market, but with protection of domestic producers
China is both the largest producer and largest consumer of thermal coal in the world. In 2017, it was
the largest importer of steam coal. China only became a net importer in the last twenty years as a
result of domestic coal shortages and the government’s decision to increase export tariffs in the
early 2000s.
China’s approach to coal pricing has vacillated between free market and protectionism for its
domestic industry, but has also been influenced by the need to clean up its poor air quality. It has
also taken steps to improve the safety record at coal mines, admittedly from a very low base.
In May 2016, China introduced measures to improve productivity at coal mines, imposing a limit of
276 working days per year (previously 330 days). Unfortunately, this measure coincided with an
increase in coal demand, so the tightening of domestic supply led to a rapid increase in imports.
By September 2016, in response to rising prices, the Chinese government reversed the working-time
limit for some 800 mines to allow increased domestic coal production through the winter.
Later that year, the government facilitated annual term contract negotiations between the largest
coal producers and generators with a benchmark price below the prevailing price of imported coal.
The immediate impact was a sharp, although temporary, reversal in the apparently inexorable rise of
international coal prices.
In this way, the government has effectively established a domestic pricing band of between 470 and
600 Yuan, with restrictions put on production if the price falls below 470 and incentives for

22.
EURACOAL page 22 of 31 17 August 2018
additional production if it reaches the upper limit. Ultimately, the Chinese policy is one of
supporting its own industry and allowing imports to provide additional supplies when required. But
by improving productivities whilst allowing a surplus of capacity to exist within the domestic coal
mining industry, China is attempting to cut and restrict the importers’ share of the market.
4.4.UK
– free market
The UK’s long history of coal mining led to a high dependence on coal-fired power generation until
the liberalisation of its electricity market and the “dash for gas” of the 1990s challenged coal’s
dominance.
Even after the privatisation of the coal industry in 1994, 3-year contracts at fixed prices plus inflation
were commonplace with the newly privatised power generators. Increasingly, however, the low
international coal prices of the late 1990s and early 2000s, alongside SO2 emission limits placed on
power generators, led to a growth in imports which showed domestic coal to be uncompetitive.
As domestic coal-supply contracts elapsed, any that were renewed were shorter term and at prices
linked to API 2. In some cases, the power generators only renewed contracts because UK ports and
the rail links from the ports could not handle sufficient volume of coal to fully displace domestic
suppliers.
Any residual domestic coal mining has virtually been killed off by the imposition of the carbon floor
price mechanism of 2013 and subsequent changes to it. In the first nine months of 2016, a mere
300 kt of coal was mined in the UK, and in 2017, less than 3 million tonnes were imported. By the
early 2020s, there will be no coal-fired power generation left in the UK.
4.5.Germany
– free market, but with protection for domestic producers
Germany has been a large producer of both hard coal and lignite for decades, although domestic
production of hard coal will finish at the end of 2018. In order for the domestic coal industry to
remain competitive with imported coal, a subsidy known at the Kohlepfennig (coal penny) was
introduced as part of the electricity tariff in 1975.
In 1995, this was scrapped and replaced by direct subsidies as part of the national budget by way of
a compromise between the federal government, the state governments, RAG AG (the largest coal
producer) and the trade unions. Subsidies in the form of operating aid have gradually been phased
out and will cease when production of German hard coal ends.
The existence of these subsidies reflected the interdependence of the German coal mining industry
and the power producers. Long-term contracts of up to 20 years known as the Jahrhundervertrag
(century contract) between coal producers and power generators were common, and the generators
sold their power under long-term contracts. German coal producers were compensated for the
difference between their production costs and the price of imported coal, so the system brought
security of supply to the generators and price stability in the electricity price (see Box 1).
4.6.Poland
– free market with cross subsidisation
Poland has a long tradition of mining coal and its entire energy system is highly dependent on coal.
For many years, Polish exports of steam coal exceeded imports which only started about ten years

23.
EURACOAL page 23 of 31 17 August 2018
ago, in 2007. Imports have steadily grown whist exports have fallen, and Poland is now a net
importer of steam coal.
Since joining the EU in 2004, Poland has had a free-market approach to coal pricing. The mining
region of Silesia is inland, close to the Czech border, meaning the growth of imports has been most
noticeable at Poland’s more northern power stations, in some cases owned by foreign companies
such as EdF. Power stations closer to the Silesian mines have continued to burn local coal.
In February 2018, the European Commission granted its approval for the Polish government to
subsidise Polish coal utililty companies through a capacity mechanism, designed to maintain the
status quo in the country’s energy system.
API 2 was already a familiar concept to Polish coal companies engaged in export, as their coals had
to compete with other coals delivered into northwest Europe at that price level. It has therefore
become commonplace for Poland to accept API 2 as the basis for market-related pricing.
4.7.Turkey
– free market, but with protection for domestic producers
Turkey has traditionally produced its own coal requirements, but imports have increased
dramatically in recent years as newly built power stations have come online. Turkey has become the
largest steam coal importer in the European Atlantic/Mediterranean basin, although quality
restrictions have prevented some potential imports.
Recently, the Turkish government introduced an import tax which comes into effect if the ARA price
(effectively API 2, but on ICE) falls below US$70/mt, in order to support local coal miners. Power
generators using domestic coal are also paid a subsidy directly from the Turkish government in order
to support the local industry.
4.8.Summary review of coal pricing systems
Seaborne coal has become a very openly traded commodity with almost full price transparency
around the globe. This transparency has led to greater efficiency in the market as buyers and sellers
all over the world can access the best pricing points. This is evidenced by recent developments such
as Colombian coal sales to India and Korea.
Most contracts are now based on indices, with additional business done as spot trades.
Countries with domestic producers have had to respond to this market transparency. They have
either forced the closure of their indigenous coal-mining industry by reducing state support (e.g. in
the UK), making domestic coal producers uncompetitive with imports, or supported coal mining with
direct subsidies or cross subsidies (e.g. Poland, Turkey and China). In all cases, they have not been
able to ignore the price of imported coal.
European countries use international coal market indicators in pricing policy decisions. Countries
that reduce production use subsidies to support local producers during the transitional period.
Pricing systems are based on market principles. Market indicators cover all major markets around
the world and reflect the balance of supply and demand in the market.
In the Asian market, traditional practices are slowly being eroded in response to changes in the
market, with less volume being transacted on fixed-price terms. China’s approach to coal pricing has
vacillated between free market and protectionism for its domestic coal industry through price
setting at a level designed to be largely competitive with imports.

24.
EURACOAL page 24 of 31 17 August 2018
Ukraine has become a net importer of low-volatile coal and needs to import this fuel. If it wishes to
support its domestic mining at the same time, it needs to recognise the impact of coal imports and
set the domestic coal price at least on a par with import prices (import parity price).
5. Coal pricing in Ukraine – advantages of market indicators
5.1.Summary
Until mid-2016, Ukraine used an administrative system to determine coal prices.
State-owned coal mines were partially reimbursed for their production costs, but no actions were
taken to promote the development of coal mining and this led to a crisis in the coal industry.
Under the current situation, there is a deficit of domestic coal supply in Ukraine. Coal has to be
imported to meet demand. The administrative pricing system is inappropriate for such
circumstances as it fails to take due account of the international market price of coal.
The international market price is very transparent and there are several, well-known and reliable
markers of relevant prices available in the market.
Other countries in similar situations either use or have used the import price as a starting point for
domestic prices so that domestic producers are offered parity with imports. Examples include
Turkey and China. Otherwise, the risk of domestic mines being forced into closure is unmanageable.
In mid-2016, the NEURC methodology was implemented to determine the price of coal delivered to
power stations based on a marker price for imported coal. This formula-based approach is a
temporary solution pending electricity market liberalisation.
After market liberalisation takes place in mid-2019, it is anticipated that a market pricing mechanism
will be implemented. If the domestic coal mining sector is not then protected from coal importers
offering market prices, it may become uncompetitive and fail.
Figure 18 – 5.2. Administrative pricing: system and consequences
No market
indicators
No real
competition
Inefficient
management
Condition for
corruption
Coal Industry
crisis
• inefficient mines reimbursed for
losses;
• unprofitable mines cross-subsidised
at the expense of profitable mines;
• no incentive for improvement in
inefficient mines;
• continuation of inefficient
management;
• potential for corruption;
• lack of investment in the
development of profitable mines;
• huge budget costs for coal
subsidies;
• deep crisis in the coal industry.
SYSTEM
RESULT
• during the coal shortage the
regulated price was lower than the
import price, which led to
discrepancies in electricity prices.
UNINTENDED
CONSEQUENCE

25.
EURACOAL page 25 of 31 17 August 2018
5.2.Ukraine became import dependent
According to economic theory, the market price is determined by supply and demand curves. In the
case of a market deficit, the price is determined by the seller, in the case of a surplus – by the buyer.
Currently, there is a coal deficit in Ukraine. During such a domestic commodity deficit, an import
parity approach to pricing should be applied to ensure a level playing field exists for the domestic
producers.
Figure 19 – Steam coal deficit In Ukraine may reach 25-30%
5.3.Analysis of the NEURC formula
Box 2 summarises the rationale and methodology behind the NEURC formula.
All over the world, countries which import coal, whether they produce coal domestically or not,
need to respond to international prices. China does this by moving its domestic price within a price
band, depending on the import price (API 8). Turkey imposes an import tax if the NWE price falls
below US$70/mt.
In order to be consistent with international coal prices, the NEURC formula requires a reliable,
transparent index for thermal coal at a location as close to Ukraine as possible.
Ukraine buys and burns both high-volatile and low-volatile thermal or steam coals. Since there is
little depth in the low-volatile steam coal market, and few international producers, there is no
reliable index for coal of this quality.
FOB (free on board) indices exist and have some liquidity (API 4, globalCOAL NEWC); other FOB
marker prices exist (e.g. API 10 (FOB Puerto Bolivar, Colombia), US East Coast, US Gulf Coast, Russian
Baltic) but are not widely used. All FOB prices are provided by fewer sellers than delivered CFR (cost
and freight) prices and reflect the reported coal prices from only one region or even one location.
API 10 is a case in point – only one seller (CMC) has access to this port.
Using a FOB index or marker price would be a reflection of the price of coal from one location and
would require freight rates from that location. These may not be readily available if there is only
limited freight traffic from that location to Ukraine.
API 2 is a delivered (CFR) marker price, at which many price offers converge, because they would not
be competitive if they did not. It captures price activity in all of northwest Europe, with many buyers
and sellers. This is why the liquidity in API 2 exceeds that of the other indices.
22.9
19
2.4
7.5
26.4 26.5
PRODUCTION 2016 CONSUMPTION 2016 PRODUCTION 2018 CONSUMPTION 2018
Domestic coal Coal import

26.
EURACOAL page 26 of 31 17 August 2018
API 2 reflects the price of coals from many sources delivered to ARA ports (Amsterdam, Rotterdam
and Antwerp), so a freight adjustment is required to reflect the delivered cost in Ukraine. The same
problem exists as with some FOB marker locations – there is too little freight traffic to determine a
delivered price.
Figure 20 – API 2 best alternative for Ukraine market indicator
Table 1 – Assessment of NEURC formula based on API 2
Arguments
in favour:
 The API 2 is transparent since it is openly traded and reported.
 It puts Ukraine in line with other countries.
 It provides a degree of certainty with a forward curve and availability of data.
 It encourages productivity improvements at poorly performing mines.
Arguments
against:
 Freight cost to Ukraine is only artificially transparent owing to a lack of coal
freight on this route, therefore freight price estimates are applied.
Possible
alternative:
 The API 2 could be used in conjunction with a fixed element to represent the
additional freight and handling costs.
 The fixed element would need to be reviewed periodically.
 It would still reflect movement in the international market, but would also
recognise the fact that Ukraine is not located in NW Europe.
5.4.Market for low-volatile coal
Some Ukrainian power plants require low-volatile coal, such as anthracite. This grade of coal is less
widely traded on the international market and attacts a price premium because it can also be used
for pulverised coal injection (PCI) in blast furnaces, reducing the need for even more expensive
89
102 102
92
80
14
16 18
24
21
API#2 API#4 API#6 API#8 API#10
Base price Transportation costs
Coal price indices 2017 with transportation costs to Ukraine, 6,000kcal,
US$/mt
103
118 120 116
102
API#2 offers the best alternative:
• Most reliable and liquid index
• Best price because CFR not FOB
• Published daily
• Made up of prices from different
locations with different qualities
• Atlantic/Mediterranean basin
• In line with other Europeans

27.
EURACOAL page 27 of 31 17 August 2018
coking coal. Given the higher cost of low-volatile coal, Ukrainian power plant owners have been
retrofitting burners to allow less expensive steam coal to be used.
Figure 21 illustrates the relative prices of steam coal delivered to northwest Europe and loaded on a
vessel in South Africa. Note that steam coal has, at times, been more expensive in South Africa than
in Europe. This is because prices in the growing Asian market have been higher than in Europe were
demand is declining. It implies negative freight rates on the once important Richards Bay to ARA
route!
Also shown in Figure 21 is the loaded price of low-volatile steam coal in Australia. The price
premium is clear, but so is the price volatility given erratic demand from the steel industry. At times,
the premium for low-volatile coal falls to zero and this product has the same value as steam coal.
Other suppliers of low-volatile coal on the international market are Vietnam, Russia and the USA.
Figure 21 – Steam coal price (CIF) at ARA ports in northwest Europe, steam coal price (FOB) at
Richards Bay Coal Terminal in South Africa and FOB price of ultra-low-volatile coal in Australia
(corrected to 6 000 kcal/kg)
Source: IHS Markit database
5.5.Transport costs to Ukraine
The choice of API 2 is justified, but reflects the costs of coal delivered to the ARA ports in northwest
Europe, not to Ukrainian ports only one of which can unload Capesize vessels (see Table 2). Expert
opinion obtained by EURACOAL agrees that shipping costs to Ukraine are higher depending on the
origin of a particular shipment and vessel size – perhaps US$9/t in the case of US coal. However,
there is very little trade upon which to confirm cost estimates. The shipping cost deltas for coal
deliverd to Ukrainian ports, rather than ARA ports, ranges from US$6.5/t to US$14.5/t according to
the NEURC methodology. Thus, the approximation of the shipping cost delta made by NEURC
reflects the actual magnitude.
0
20
40
60
80
100
120
140
160
180
200
ULV PCI Aus FOB
RB FOB
NWE CIF
US$/tonne 6 000 kcal/kg NAR

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EURACOAL page 28 of 31 17 August 2018
Table 2 – Capacity of Ukrainian coal-handling ports
Port Max. ship size, kt Import capacity, Mtpa Export capacity, Mtpa
TIS – coal 75 3.7 28.0
Yuzhniy 180 2.8 17.0
Chernomorsk 75 2.4 15.0
Nikolaev 37.5 0.5 15.0
Mariupol (Sea of Azov) 20 1.4 11.0
Berdyansk (Sea of Azov) 20 0.8 10.0
Total 11.6 96.0
Note that using the API 2 price index plus a cost add-on for transport, the so-called Rotterdam+
price, does not imply that coal is or would ever be shipped from ARA ports to Ukraine. That would
be ridiculous! Coal is shipped from producer countries such as Colombia, the USA or South Africa
directly to Ukraine, but at a higher transport cost than the more popular routes to northwest
Europe.
5.6.Sulphur content of coal
API 2 is based on the following quality: steam coal with 6 000 kcal/kg NAR (net as received), sulphur
<=1% as received. Most of the coal from Ukrainian mines has a sulphur content >1%.
The formula price calculation does not include any discount for sulphur content for the following
reasons:
 The Ukrainian government permits the sale and purchase of coal with sulphur content >1%
for the power sector without any restrictions and/or discounts. TPPs pay a high ecological
tax to the state for sulphur dioxide emissions (see Table 3). However, there is no regulatory
framework to set a discount to the price of coal with a lower sulphur content.
 Ultimately, the largest proportion of coal imports to Ukraine do have a low sulphur content.
The import parity price therefore provides an appropriate and correct indication of the price
of alternative coal to Ukraine.
 Many countries with domestic coal production and a net import position use support
mechanisms for local producers through subsidies, taxes and price regulation. The
implementation of the coal price setting mechanism in Ukraine does not penalise local
producers for the inherent sulphur content of Ukrainian coal. Fundamental economics
support this logic: there is no discrimination against local producers for uncontrollable
quality factors (an element of protectionism), while the government receives long-term
benefits through increasing local production and restricting the growth of imports.
Table 3 – Ecological taxes on air pollutants from thermal power plants in Ukraine, UAH/tonne
2015 2016 2017 2018
SO2 1 165 1 969 2 205 2 452
NOx 1 165 1 969 2 205 2 452
The tax on SO2 in 2018 was equivalent to a coal tax of 49 UAH/tonne (c.US$1.80/tonne) per 1% sulphur.

29.
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6. Key findings
Coal is a widely and openly traded commodity with transparent prices for the main market hubs;
therefore, assessing the current price of steam coal is a fairly simple task.
Most countries have moved towards market-based energy price setting, although Europe has
generally moved further with this than Asian countries.
Most of the of the world trades coal on a free-market basis, largely spot-based contracts, but with
some residual term (annual) business in Asia. Index-linked contracts are common, because they
provide security of supply of a suitable product at a price that is always relevant to the current
market price.
Almost all European coal business is transacted with a reference – direct or indirect – to API 2. This
index is also widely used as the settlement basis for financial transactions, allowing participants to
hedge their exposure to price risks.
Countries whose domestic coal production is in managed decline have used European benchmark
prices as the best indicator of the relevant price for the equivalent commodity. If buyers of coal
have the freedom to buy at the best possible price, then in times of low international prices
domestic suppliers will be unable to compete without support mechanisms.
In Ukraine, price setting is regulated by the government using the NEURC methodology and relies on
the NW European coal hub marker price – API 2 index
This is appropriate in the current European market as there are few, if any examples of European
countries whose coal price is NOT assessed against API 2.
The API 2 is the best indicator for coal price changes for Ukraine for the following reasons:
 It is the most liquid index in the world.
 It is highly transparent.
 It is independently verifiable and includes a large number of prices provided by both buyers
and sellers.
 It is a “delivered index” which inevitably produces more competitive pricing than FOB price
indices which only reflect the pricing activity at one location.
 The most liquid FOB index is API 4 which is influenced by Asian trades as well as European,
so is less relevant to Ukraine.
 Using an FOB index would limit the price methodology to coal from one location and would
require freight assessments as well.
 Ukraine is part of Europe, so the location is in the appropriate trading basin
(Atlantic/Mediterranean).
An alternative approach would be to include an element of fixed transport cost, subject to
reassessment after pre-agreed time periods, to represent the “on-costs” from ARA, on top of the
variable API 2.

30.
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7. Conclusions
It would be counter-intuitive and against the “direction of world travel” for Ukraine to move away
from a market-based pricing system.
Coal importing countries all over the world are moving towards more dynamic pricing, and even very
conservative societies such as Japan are reducing their dependence on long-term contracts and
buying more coal at spot prices.
Ukraine’s other imported energy commodities, such as oil and gas, are priced in this way, and this
approach has IMF backing.
In some countries, such as the UK, a refusal to accept import parity pricing led to the bankruptcy of
the indigenous coal industry.
Of the alternatives available, the arguments in favour of the API 2 are compelling.
API 2 provides independence, consistency, reliability and a mechanism by which price risk can be
managed through hedging.
It also provides transparency with a forward curve, offering investors a more stable environment.
If a market-based system is to be introduced when the electricity market is liberalised, then it is
entirely consistent to continue with a market-based approach in the meantime.

31.
EURACOAL page 31 of 31 17 August 2018
Annex 1 – English translation of NEURC Resolution No. 289
on a Procedure for the Calculation of the Forecast
Wholesale Market Price of Electricity

32.
English translation by EURACOAL of Ukrainian original
NATIONAL ENERGY AND UTILITIES REGULATORY
COMMISSION OF UKRAINE
RESOLUTION
03.03.2016 No. 289
Registered at the Ministry of
Justice of Ukraine
on 23 March 2016
under No. 428/28558
On the Approval of a Procedure for the Calculation of the
Forecast Wholesale Market Price of Electricity
In accordance with the fifth paragraph of the first part of Article 12 of the Law of Ukraine “On
Electricity” and the fifth paragraph of sub-clause 5 of clause 4 of the Regulation on the National
Energy and Utilities Regulatory Commission, approved by the Decree of the President of Ukraine
No. 715 of 10 September 2014, the National Energy and Utilities Regulatory Commission,
RESOLVES:
1. To approve the attached Procedure for the calculation of the projected wholesale market
price of electricity.
2. To ensure submission of this resolution to the Ministry of Justice of Ukraine for state
registration in accordance with the established procedure.
3. This resolution enters into force from the day of its official publication.
Chairman of the Commission D. Vovk
APPROVED BY:
The Minister of Energy
and Coal Mining Industry of Ukraine V. Demchyshyn
The Chairman of the
Anti-monopoly Commission of Ukraine Yu. Terentiev
The Chairman of the State Regulatory Service of Ukraine K. M. Liapina

33.
English translation by EURACOAL of Ukrainian original
APPROVED BY
Resolution of the National
Energy and Utilities Regulatory
Commission of Ukraine
03.03.2016 No. 289
Registered at the Ministry of
Justice of Ukraine
on 23 March 2016
under No. 428/28558
PROCEDURE
for the Calculation of the Forecast Wholesale Market Price of Electricity
I. General provisions
1.1. This Procedure determines the mechanism for calculating the forecast wholesale market
price of electricity, the procedure for its approval and its revision.
1.2. This Procedure is applied by NEURC for the calculation and approval of the forecast
wholesale market price of electricity (hereinafter referred to as the forecast wholesale market price)
and applies to all business entities engaged in the production and supply of electricity.
1.3. In this Procedure the following symbols are used:
b - specific consumption of conventional fuel equivalent, in accordance with the actual
consumption in the forecast structure of fuel for thermal power stations for the relevant period,
calculated by the central executive authority which implements the state policy in the electricity
sector according to the forecast balance of electricity in the United Energy System of Ukraine
(hereinafter referred to as the UES of Ukraine). In the absence of consumption determined by the
central executive authority which implements the state policy in the electricity sector, the
consumption based on reported data for the 12 months preceding the month of calculation and
approval of the forecast wholesale market price, according to the Form 1-NERC (monthly) “Report
on the use of fuel by the licensee for the production of heat and electricity”, approved by Resolution
No. 1257 of the National Energy Regulatory Commission on 4 October 2012, registered with the
Ministry of Justice of Ukraine on 26 October 2012 under No. 1791/22103 (as amended), grammes
of fuel equivalent (g.f.e.) / kWh (hereinafter referred to as Form 1-NERC);
n - the rate of return for electricity generators (hereinafter referred to as Generators) which
operate on the basis of variable-cost bidding for a settlement period, which allows profitable
activity for the production of electricity, %;
е
кr - percentage of conventional fuel equivalent used for electricity production, calculated on
the basis of the forecast structure of fuel for thermal power plants for the relevant period, calculated
by the central executive authority which implements the state policy in the electricity sector,
according to the forecast balance of electricity in the UES of Ukraine. In the absence of the forecast
structure of fuel for thermal power plants – then based on the reporting data for the 12 months
preceding the month of calculation and approval of the forecast wholesale market price, according
to the Form 1-NERC, %;
в - Generator sub-index;
эр
рД - cost estimates for “Energorynok” SE, UAH;
пв
рД - forecast amount of subsidies to compensate for losses from the provision of electricity
supply at the regulated tariff, UAH;

34.
English translation by EURACOAL of Ukrainian original
рек
рД - additional payment to the Generators who operate though variable-cost bidding for the
reconstruction and modernisation of their power plant equipment, UAH;
імп
рД - payment to operators of external sources for electricity imported into the Wholesale
Electricity Market of Ukraine (hereinafter referred to as WEM), UAH;
ап
рД - forecast amount of excise tax, UAH;
зб
рД - additional payments to Generators who operate under variable-cost bidding for
compliance with legislative acts and executive decisions, repayment of bad debt, UAH;
упв
рД - allowable fixed costs for the settlement period for the Generators who operate under
variable-cost bidding, UAH;
упвф
Д - actual allowable fixed costs of the Generators operating under variable-cost bidding,
based on data for the 12 months preceding the settlement month and approval of the forecast
wholesale market price, according to the Form 6-NERC on (quarterly) energy production “Report
on the licensed activities of business entities engaged in the production of heat and electricity”,
approved by Resolution No. 1257 of the National Energy Regulatory Commission on 4 October
2012,, registered with the Ministry of Justice of Ukraine on 26 October 2012 under No. 1791/22103
(as amended), UAH;
п
рД - forecast cost of fuel to be used by the Generators who operate under variable-cost bidding
in the settlement period for the production of electricity, UAH;
т
врЕ - the volume of electricity sales in the WEM by the Generators who do not operate under
variable-cost bidding, MWh;
цз
рЕ - the volume of electricity sales in the WEM by Generators operating under variable-cost
bidding, MWh;
імп
оірЕ - the volume of electricity imported into the WEM by the operator of the external source
with the i-th external flow, UAH;
мм
рЕ - the volume of electricity transmitted over the national transmission and cross-border
electricity networks, MWh;
ммв
рЕ - the volume of technical power losses in the national transmission and cross-border
electricity networks, MWh;
рІЦВ - forecast index of industrial producer prices for the settlement period in accordance with
the forecast of economic and social development of Ukraine and the main macroeconomic
indicators of the economic and social development of Ukraine, approved by the Cabinet of
Ministers of Ukraine, %;
ап
К - rate of excise tax, determined by the Tax Code of Ukraine, %;
Q
кК - the calorific equivalent for the conversion of a fuel into its conventional fuel equivalent,
relative units;
к - type of fossil fuel (coal, gas, fuel oil), sub-index;
р - planning period of one calendar year with a quarterly breakdown;
т
врТ - tariff for electricity sales in the WEM for a Generator who does not operated through
variable-cost bidding, UAH / MWh;
імп
оірТ - selling price in the WEM for electricity imported by the operator of the external source
with the i-th external flow, UAH / MWh;

35.
English translation by EURACOAL of Ukrainian original
мм
рТ - tariff for electricity transmitted over the national transmission and cross-border
electricity networks, including payment for the central dispatch control of the UES of Ukraine,
UAH / MWh;
цз
рЦ - price of electricity sales in the WEM for the Generators operating under variable-cost
bidding, UAH / MWh;
упе
Ц - average weighted price of conventional fuel equivalent for the production of electricity,
UAH / t of conventional fuel equivalent;
пор
рЦ - forecast wholesale market price, UAH / MWh.
Other terms in this Procedure shall have the meanings set forth in the Law of Ukraine “On
Electricity”, the Agreement between the Members of the Wholesale Electricity Market of Ukraine
of 15 November 1996 and its annexes.
II. The mechanism for calculating the forecast wholesale market price
2.1. The forecast wholesale market price is calculated by NEURC on the basis of the forecast
balance of electricity in the UES of Ukraine, approved by the central executive authority that
implements the state policy in the electricity sector, the forecast volumes of electricity supply in the
Wholesale Electricity Market and forecast fuel structure of thermal power plants for the relevant
period, calculated by the central executive authority that implements state policy in the electricity
sector, according to the forecast balance of electricity in the UES of Ukraine.
2.2. The forecast wholesale market price is calculated on the basis of:
1) sales tariffs for electricity in the WEM approved by NEURC for the Generators who operate
under variable-cost bidding ( т
врТ );
2) the sales prices in the WEM of electricity imported by operators of external sources,
approved by NEURC ( імп
оірТ );
3) the tariff for transmission of electricity by the national transmission and cross-border
electricity networks, including payment for the central dispatch control of the UES of Ukraine,
approved by NEURC ( мм
рТ );
4) the selling price of electricity in the WEM for the Generators who operate under variable-
cost bidding ( цз
pЦ );
5) the volumes of electricity sales in the WEM by the Generators who do not operate under
variable-cost bidding in accordance with the approved forecast electricity balance of the UES of
Ukraine ( т
врЕ );
6) the volumes of electricity sales in the WEM by the Generators operating under variable-cost
bidding in accordance with the approved forecast electricity balance of the UES of Ukraine ( цз
рЕ );
7) the volume of electricity imported into the WEM by operators of external sources in
accordance with the approved forecast electricity balance of the UES of Ukraine ( імп
оірЕ );
8) the volume of power transmitted by the national transmission and cross-border electricity
networks in accordance with the approved forecast electricity balance of the UES of Ukraine
( мм
рЕ );
9) the volume of technical power losses in the national transmission and cross-border electricity
networks in accordance with the approved forecast electricity balance of the UES of Ukraine
( ммв
рЕ );

36.
English translation by EURACOAL of Ukrainian original
10) cost estimates for “Energorynok” SE, approved by NEURC ( эр
рД );
11) the forecast amount of subsidies to compensate for the losses due to the provision of
electricity supply at a regulated tariff ( пв
рД );
12) the additional payments to the Generators who operate under variable-cost bidding for the
reconstruction and modernisation of their power plant equipment ( рек
рД );
13) the forecast amount of excise tax ( ап
рД );
14) the additional payments to the Generators who operate under variable-cost bidding for
compliance with legislative acts and executive decisions, repayment of bad debt ( зб
рД );
15) the rate of excise tax, as determined by the Tax Code of Ukraine ( ап
К ).
2.3. The forecast wholesale market price is calculated on the basis of the cost of electricity
purchased by the WEM from the Generators, taking into account the cost of imported electricity,
the costs of dispatch and maintenance of the national transmission grid and cross-border
interconnectors, payment for the services of “Energorynok” SE, payments to the Generators for the
reconstruction and modernisation of their power plant equipment, the forecast amount of excise tax,
payments for to compensate for the losses from the actual supply of electricity at a regulated tariff,
payments to the Generators for compliance with legislative acts and executive decisions.
2.4. The price and cost indicators, on the basis of which the forecast wholesale market price is
calculated, shall be applied without taking into account value added tax.
III. Calculation of the forecast wholesale market price and payments to Generators for whom
the price applies
3.1. The forecast price of electricity sales in the WEM by the Generators operating under
variable-cost bidding is calculated according to the formula:
цз
р
п
р
упв
р
цз
р
Е
)
100
n
(1)Д(Д
Ц

 ,
where ),
100
ІЦВ
(1ДД
рупвфупв
р 
1000
ЕbЦ
Д
цз
р
упе
п
р

 ,
where 





  100
r
K
Ц
Ц
e
к
Q
к
нп
к
к
упе
,
where нп
кЦ - the price of fossil fuel (coal, gas, fuel oil), which is determined as follows:
for steam coal – according to the following formula:
втвіннп
к ЦЦЦ  ,
where він
Ц - the indicative price of coal, which is determined on the basis of the average market
price on the European market (based on API 2 being the average CIF index at the
main ports in Western Europe: Amsterdam-Rotterdam-Antwerp) for the 12 months
preceding the settlement month of the forecast of the wholesale market price, which
is calculated taking into account the average rate on the interbank market (at the date
of establishing the official hryvnia exchange rate) published on the official website

37.
English translation by EURACOAL of Ukrainian original
of the National Bank of Ukraine on the settlement date and is brought in line with the
calorific value of domestic coal in the forecast fuel mix for thermal power stations
for the corresponding period, as calculated by the central executive authority which
implements the state policy in the electricity sector, according to the forecast
electricity balance of the UES of Ukraine;
вт
Ц - the price of coal transport, which is determined according to the following formula:
злперфрвт
ЦЦЦЦ  ,
where фр
Ц - the average cost of delivery of coal from the ports of Amsterdam-Rotterdam-
Antwerp to Ukrainian ports for the 12 months preceding the month of setting the
forecast wholesale market price, which is calculated on the basis of data collected
from the state authorities responsible for monitoring prices or on the basis of data
published in relevant printed publications;
пер
Ц - the average cost of unloading coal from a vessel to the stockyards at Ukrainian ports
for the 12 months preceding the month of setting the forecast wholesale market price,
which is calculated on the basis of data collected from the state authorities
responsible for monitoring prices or on the basis of data published in relevant printed
publications;
зл
Ц - the cost of transporting coal by rail through the territory of Ukraine, calculated on the
basis of data for the 12 months preceding the settlement month and approval of the
forecast wholesale market price, according to the Form 1-NERC (including transport
costs) and taking into account the forecast of its growth over the settlement period,
provided by the “Ukrainian Railways” public joint stock company, UAH / tonne;
for natural gas and fuel oil – based on the data for the 12 months preceding the
settlement month and approval of the forecast wholesale market price, according to
the Form 1-NERC (including transport costs), UAH / thousand m³, UAH / t.
3.2. Forecast payments to the Generators who operate under variable-cost bidding are
calculated according to the formula:
цз
р
цз
р
цз
р ЕЦД  .
V. Calculation of the forecast wholesale market price and its components
4.1. Forecast payments to the Generators who do not operate under variable-cost bidding are
calculated according to the following formula:
  
в
т
вр
т
вр
т
р ЕТД .
4.2. Forecast payments to operators of external sources are calculated according to the
following formula:
  
о і
імп
оір
імп
оір
імп
р ЕТД .
4.3. Forecast payments for carrying out central dispatch and the use of the national transmission
grid and cross-border interconnectors are calculated according to the following formula:
мм
р
мм
р
мм
р ЕТД  .
4.4. The forecast amount of the excise tax is calculated according to the following formula:
100
К
)ДДДДДД(ДД
ап
зб
р
рек
р
імп
р
мм
р
эр
р
т
р
цз
р
ап
р  .

38.
English translation by EURACOAL of Ukrainian original
4.5. The forecast wholesale market price is calculated according to the following formula:
ммв
р
о і
імп
оір
в
т
вр
цз
р
ап
р
зб
р
рек
р
эр
р
пв
р
мм
р
імп
р
т
р
цз
рпор
р
ЕЕЕЕ
ДДДДДДДДД
Ц




V. Procedure for approval and revision of the forecast wholesale market price
5.1. The NEURC shall, no later than 10 days prior to the start of the planning period, approve
the forecast wholesale market price for the settlement year (quarterly) and no later than 10 days
prior to the start of the planning period shall inform electricity suppliers and the wholesale supplier
of electricity.
5.2. In order to comply with the indicators determined in accordance with this Procedure, the
approved forecast wholesale market price shall be reviewed quarterly, 5 days prior to the start of the
settlement quarter, provided that the indicators used in calculating the forecast wholesale market
price (including those for the previous settlement periods) result in a change in the annual forecast
market price of more than 5%.
Head of the
Energy Market Department T. E. Revenko
Document promulgation:
Officially published in the “Uryadovy Kuryer” (Governmental Courier), 30.03.2016, No. 60
Official Gazette of Ukraine, 8 April 2016, No. 26, p.323, Article 1063, Act Code 81308/2016